State v. Chappell
127 Ohio St. 3d 376
Ohio2010Background
- This case concerns the meaning of the term “criminally” in R.C. 2923.24(A), which prohibits possessing criminal tools with purpose to use them criminally.
- The State argues the plain meaning encompasses all criminal purposes, including violations of federal law, not just Ohio law.
- Chappell argues the purpose to use must be limited to offenses defined in the Ohio Revised Code and that federal-law violations cannot support a state prosecution.
- The State asserted it could prove intent to violate federal copyright law under 17 U.S.C. § 506 as the underlying purpose.
- Chappell moved to dismiss; the trial court dismissed the criminal-tools count, and the Eighth District affirmed that dismissal.
- The Supreme Court accepted discretionary review to decide whether violations of federal criminal law may prove possession of tools under R.C. 2923.24.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ‘criminally’ in R.C. 2923.24(A) includes federal-law violations | State: plain meaning includes violations of any law. | Chappell: only Ohio-law offenses may support possession of tools. | Yes; ‘criminally’ encompasses violations of federal law. |
| Whether federal-law violations can be the underlying intent to use tools to convict under R.C. 2923.24 | State: proof of intent to violate federal law can sustain the offense. | Chappell: cannot prosecute for federal-law violations under an Ohio-tools statute. | Yes; the state may prove intent to violate federal law to convict under R.C. 2923.24. |
Key Cases Cited
- State v. Hairston, 101 Ohio St.3d 308 (2004-Ohio-969) (statutory construction aims to discern legislative intent from plain language)
- State v. Anthony, 96 Ohio St.3d 173 (2002-Ohio-4008) (plain meaning and ambiguity determine interpretation)
- Bailey v. Republic Engineered Steels, Inc., 91 Ohio St.3d 38 (2001-Ohio-741) (strict construction against the state; liberal in favor of the accused)
- Slingluff v. Weaver, 66 Ohio St. 621 (1902) (statutory interpretation principles and purpose of the law)
- Niskanen v. Giant Eagle, Inc., 122 Ohio St.3d 486 (2009-Ohio-3626) (issues raised must be properly before the court; avoid unnecessary rulings)
- Maxfield v. Brooks, 110 Ohio St. 566 (1924) (parity of statutory construction principles in related provisions)